Governance
Compliance management system
1. CODES OF CONDUCT AND DIRECTIVES
Implenia defines its underlying values as a responsible business in its “How We Work” Code of Conduct: excellence, collaboration, agility, integrity and sustainability. The Code governs the way employees relate to each other, but also in the way they deal with business partners, authorities and the environment.
Implenia has also issued binding directives throughout the Group and introduced standards and processes. Together with the Code of Conduct, these ensure that ethical conduct and compliance with the law govern all activities within the company.
In 2023, Implenia introduced an independent Code of Conduct for External Business Partners. This defines the most important principles and specific conditions for cooperation with business partners. It focuses on working conditions, human rights, fair and respectful treatment of employees, ethical business practices, responsible supply chains, environmental protection and sustainable procurement. The Code of Conduct for External Business Partners is an integral part of all agreements between Implenia and its business partners.
1.1 Organisation
The Group’s Chief Compliance Officer and General Counsel is the compliance specialist on the Implenia Executive Committee. They report here and at every meeting of the Audit Committee on the latest compliance issues. They are supported by the Global Head of the Compliance & Data Protection Department, whose responsibilities include implementation of the compliance management system.
Responsibility for regional issues within individual countries lies with Country Compliance Officers and Data Protection Coordinators and Officers. They act as first points of contact for questions about legal and regulatory compliance, and receive initial reports on suspected irregularities. Together, they ensure that Implenia’s compliance standards are consistently applied across all markets.
1.2 Training and awareness raising
Following the introduction of the revised “How We Work” Code of Conduct in 2023, all technical-commercial staff completed a mandatory e-learning programme on the content of the Code in 2024. This training has now become a fixed part of the new employee onboarding process, ensuring a consistent understanding the core values and compliance obligations from the outset.
Refresher training on the Code of Conduct is held regularly, supplemented by key legal and ethical topics such as competition law, conflicts of interest and corruption prevention. These measures strengthen the company-wide compliance culture.
Office-based employees completed e-learning courses on various compliance issues in 2025 . Nearly 800 employees took part in Code of Conduct training, around 900 completed an e-learning course on data protection, and around 1,800 completed training on anti-corruption and bribery. As well as the e-learning, in-person training was held at local and Group-wide seminars, while tailored training sessions were delivered at offices and on construction sites.
To keep the principles of the Code of Conduct at the forefront of people’s minds, Implenia regularly carries out awareness-raising campaigns. These address subjects such as how to handle gifts and invitations. The company has developed “Quick Guides” on common questions, e.g. rules of conduct at trade association meetings, video surveillance on construction sites and dealing with conflicts of interest. They offer employees handy guidance while at work.
Anti-corruption communication and training (in % of employees trained/reached)
| 2025 | 2024 | 2023 | |
|---|---|---|---|
| Type | % of employees | % of employees | % of employees |
| Anti-corruption communication | 58 | 60 | 58 |
| Anti-corruption training | 13 | 60 | 13 |
Note on anti-corruption communication: All technical-commercial employees received communication on anti-corruption topics in the years 2022-2025.
Note on anti-corruption training:In 2024, the Code of Conduct training for all technical-commercial employees was refreshed. As a result, the number of trained employees was particularly high in the previous year. Another training programme, which is mandatory for all technical-commercial employees, was rolled out at the end of 2025. The deadline for completion is 2026.
Code of Conduct - e-learning (number)
| 2025 | 2024 | 2023 | |
|---|---|---|---|
| Completed e-learning courses | 2 904 | 10 398 | 993 |
Note on Code of Conduct - e-learning 2025: This number includes CoC training, LkSG training for relevant office staff in Germany and data protection training. All office staff are required to complete Code of Conduct and data protection training when they start work at Implenia. On-site employees are trained using a risk-based approach focusing in particular on health and safety, including basic compliance issues. In 2024, the Code of Conduct training for all technical-commercial employees was refreshed. As a result, the number of trained employees was particularly high in the previous year.
1.3 Possible compliance violations
Implenia encourages all individuals to report possible violations of the Code of Conduct, other internal policies or the law. Various channels are available for this, including the Implenia Speak Up Line – a whistleblower platform operated by an external organisation. This platform also enables anonymous reporting via a publicly accessible website and provides an option to communicate with the whistleblower. All reports are investigated comprehensively and neutrally. The protection of whistleblowers from discrimination or punishment is a central feature of the process.
If suspicions are confirmed by an initial review, the responsible Country Compliance Officer or Global Head of Compliance & Data Protection conducts an in-depth investigation in consultation with the Chief Compliance Officer. If reports concern Implenia’s supply chain, a member of Procurement and the Implenia Human Rights Officer are also brought into the process (see “Human Rights” chapter). Results are documented and presented to the responsible body for them to make a decision.
A total of 42 reports were received across the Group in 2025. These concerned sexual harassment, fraud, discrimination, possible conflicts of interest and other matters. The reports have been investigated and appropriate action taken where required. In addition, six suspected cases of corruption were reported. Three reports could not be substantiated or were proven to be baseless, while three others are still under investigation.
Fighting corruption and anti-competitive behaviour
The construction and real estate industry is highly competitive. Implenia competes fairly, pursuing a zero-tolerance policy against anti-competitive behaviour and rejecting any form of corruption. Clear rules about who has the power to make decisions and who should be informed of them, plus the “two-pairs-of-eyes principle”, act as essential bulwarks against corruption. As part of the standard auditing process, auditors also check the consolidated accounts for any irregularities.
The anti-corruption principles in the “How we work” Code of Conduct are turned into concrete rules by a Group-wide integrity directive, which was revised in 2025. The directive contains binding instructions on preventing and actively fighting against corruption. The global integrity directive also sets out clear guidelines for giving and receiving personal gifts or invitations to events. It stipulates country-specific upper limits, above which gifts and events either have to be approved or are forbidden.
Implenia has formulated a Group-wide competition directive to help familiarise employees with competition law requirements and protect them from accidental infringements. This contains unambiguous rules, prohibits any agreements that could violate competition law, and shows employees how to conduct themselves in accordance with the law.
Infringements of competition law
If Implenia is implicated in investigations or lawsuits relating to competition law, it cooperates fully with the authorities and provides transparent information about the matter concerned. Since 2010, a total of five official investigations have taken place, two of which were closed some time ago. Implenia dealt with three outstanding cases during the period under review:
- In Switzerland, the Competition Commission carried out several investigations in the canton of Grisons between 2010 and 2019. These concerned suspicions of illegal collusion in the road construction market as well as in building construction and civil engineering prior to 2010. Implenia gave the Competition Commission its unreserved cooperation throughout the process and helped with the investigation into the price and territory agreements concerned. The investigating authorities therefore refrained from imposing a fine on Implenia in the main investigation. The main investigation was subsequently divided into several sub-inquiries. In two of these, the Competition Commission refused to recognise Implenia as a principle witness and imposed fines for alleged collusion on two smaller building projects. Implenia appealed to the Federal Administrative Court against this refusal and against the division of proceedings. This appeal was dismissed, so Implenia appealed to the Federal Supreme Court, where the case is still pending.
- In Austria, the Central Public Prosecutor’s Office for Combating Economic Crime and Corruption in Vienna has been conducting an investigation into suspected collusive bidding since 2017; Implenia Baugesellschaft GmbH is one of the companies it is looking at. The investigation is still under way.
- In March 2024, the Swiss Competition Commission broadened its investigation into possible collusion in civil engineering and building construction in the canton of Neuchâtel, which was originally launched in November 2023. The investigation was extended from the original three to more than 20 companies, including Implenia. The Commission is investigating whether there was collusion on offers and pricing for civil engineering tenders put out by public and private clients between 2009 and 2024. Implenia has assured the Competition Commission of its full cooperation.
Information on older cases can be found in previous sustainability reports.
Human rights
Respect for human rights is an important concern for Implenia as it meets its corporate responsibilities. The company’s commitment here is based on the United Nations Universal Declaration of Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work. In its Policy Declaration Implenia pledges its respect for, among other things, internationally recognised human rights, and commits to uphold them in its business activities along the entire value chain.
Implenia has pledged to comply with the following international conventions:
- United Nations Universal Declaration of Human Rights
- International Covenant on Civil and Political Rights
- International Covenant on Economic, Social and Cultural Rights
- The International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work and its follow-up declaration
- Ten principles of the UN Global Compact
- United Nations Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
Implenia has implemented the following due diligence procedures across its whole supply chain to stop or redress human rights violations:
- Internal, global purchasing rules require that human rights and selected environmental criteria are applied when choosing and evaluating suppliers; self-declarations are required from suppliers to confirm they are meeting country-specific legal standards
- Supplier audits including appropriate control measures
- Obtaining self-declarations from suppliers
- The Code of Conduct for External Business Partners is integrated into current and future supplier agreements, which ensures there is a contractual obligation on suppliers to comply with human rights and environmental due diligence obligations
- Relevant office staff are trained educated about due diligence processes in the supply chain through e-learning courses
- Consistent implementation of measures to ensure that every employee is working in a safe working environment. This includes regular training to raise awareness of potential risks, and the provision of protective equipment
- Strict controls and policies are applied to minimise accidents and risks to health.
Implenia promotes a culture that encourages employees and people outside the company, to report possible cases of misconduct, including concerns or suspicions relating to human rights violations within the company. The anonymous Speak Up Line (see chapter on the Compliance Management System) is one channel for such reports.
If there are concerns about or signs of possible violations in the supply chain, the Human Rights Officer will investigate with the help of representatives from Procurement and the Legal & Compliance Department. Investigations take place digitally in accordance with a transparent process set out in the rules of the Speak Up Line. If necessary, the Human Rights Officer will consult other people from the Divisions, global functions and countries.
Implenia has set out clear rules against child and forced labour in the “How we work” Code of Conduct, which is mandatory for all employees, and in the Code of Conduct for External Business Partners. A comprehensive regulation on this topic is also contained in the policy declaration on human rights strategy adopted by Implenia. This takes legal requirements along the entire value chain into account (read more).
An internal risk analysis carried out in 2024 revealed no reasonable suspicion of child labour at Implenia or in its supply chain, so Implenia is exempted from due diligence and reporting obligations in the field of child labour in accordance with the Ordinance on Due Diligence and Transparency (VSoTr). A new analysis in 2025 confirmed this outcome.
Supplier management
Implenia purchases a substantial volume of steel, concrete and other building materials for its projects, as well as buying in various services from business partners. More than 98% of these suppliers are based in the EU or Switzerland.
The company uses a professional supplier management system to minimise risks along its complex value chain. All suppliers and subcontractors go through a multi-step process that forms the basis for a trusting long-term working relationship. This includes due diligence checks, (re-)qualifications, annual evaluations and assessments, plus other supplier development measures.
All business partners must meet clearly defined minimum requirements in the following areas:
- Environment
- Working conditions
- Occupational health and safety
- Compliance
- Procurement
- Quality
- Financial performance
A sustainability index is created for each business partner to measure its sustainability performance. This is based on an evaluation of various criteria such as quality, occupational safety, environmental management and compliance. Internal project evaluations and empirical values are also considered in the assessment. Implenia continuously collects relevant data and trains employees in the application of the index when awarding contracts.
If the supplier achieves a set score in the index, it is classified as sustainable.
The most important suppliers have been comprehensively evaluated in Switzerland, Germany, Sweden and Norway; supplier assessments were also carried out in these countries last year. Assessments were carried out in Austria, Italy and France as part of joint ventures.
Supplier Relationship Management (SRM) data shows that in 2025, around 75% of the total paid to suppliers went to business partners who are assessed according to sustainability criteria and meet stricter requirements.
Risk analysis compliant with the Supply Chain Due Diligence Act, which has applied to Implenia in Germany since the beginning of 2024, is also covered by the new SRM system. This means that Implenia always has up-to-date and reliable information on its business partners in Germany and Switzerland, where about 95% of these partners are based.
In addition to the SRM, Implenia is currently developing Group-wide procurement guidelines, which will be expanded to include additional sustainability criteria.
Evaluated suppliers and subcontractors (in amount and %)
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Total number of suppliers and subcontractors | 5 238 | 4 564 | 5 120 | 3 536 | 4 942 |
| Percentage of suppliers and subcontractors who commit to the minimum environmental and social requirements under the Code of Conduct or the Code of Conduct for External Business Partners | 100% | 100% | 100% | 100% | 100% |
Note for 2021-2022: Data for Switzerland.
Note for 2023-2025: Data for Switzerland and Germany.
Note on percentage: All business partners working on Implenia construction sites are contractually obliged to comply with clearly defined minimum requirements, based on the Code of Conduct, in the areas of environment, working conditions, health and safety at work, quality, procurement and finance. In 2023, Implenia published its Code of Conduct for External Business Partners, which forms part of all new contracts with external parties. The document specifies the requirements of the Code of Conduct for Implenia’s business partners with regard to business integrity, human rights and working conditions, environmental protection and management systems.
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